Point Legal Privacy Policy

PRIVACY POLICY

(A) This Policy

This Policy is issued by Point Legal, a consultancy firm registered as P.K.Z. Your Point Services Ltd. In Cyprus, ("Point",“we”, or “us”) and using the following website: https://thepointlegal.com/ (“Site”).

This Policy is addressed to individuals outside our organisation with whom we interact, including individual clients, representatives of client organisations, visitors to our Site and other users of our services (together, “you”).

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

(B) Collection of Personal Data

We may collect or obtain Personal Data about you:

1. directly from you (e.g., where you contact us);
2. in the course of our relationship with you (e.g., if we provide services to you);
3. when you make your Personal Data public (e.g., if you make a public post on social media);
4. when you visit our Site;
5. when you register to use any of our services; or
6. when you interact with any third party content or advertising on a Site or in an App.

We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

(C) Creation of Personal Data

We may create Personal Data about you (e.g., records of your interactions with us).

We may also create Personal Data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.

(D) Categories of Personal Data we may Process

We may Process:

1. your personal details (e.g., your name);
2. demographic data (e.g., your age);
3. your contact details (e.g., your address);
4. matter details (e.g., your instructions to us);
5. records of your consents to our Processing of your Personal Data;
6. payment details (e.g., your billing address);
7. information about your use of our Site (e.g., the type of device you are using);
8. details of your current employer;
9. information about your interactions with our content or advertising;and
10. any views or opinions you provide to us.

(E) Sensitive Personal Data

We may have to Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

1. Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
2. Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
3. Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
4. Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is not used in relation to Processing that we are legally required to carry out).

(F) Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(G) Disclosure of Personal Data to third parties

We may disclose your Personal Data, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy, to:

1. legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
2. accountants, auditors, lawyers and other outside professional advisors to the Point, subject to binding contractual obligations of confidentiality;
3. third party Processors (such as providers of data hosting services and document review services), located anywhere in the world, subject to the requirements noted below in this Section (G);
4. any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
5. any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
6. any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
7. any relevant third party provider, where our Site uses third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to:

1. only Process the Personal Data in accordance with our prior written instructions; and
2. apply measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

(H) International transfer of Personal Data

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA or the UK to a recipient outside the EEA or the UK that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

We use cloud hosted services for some of our systems, which may include document management, email and collaboration systems. Personal Data provided to us or created and processed on your behalf may be stored in these cloud hosted services.

(I) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(J) Data accuracy

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(K) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(L) Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

(M) Your legal rights

Under applicable law, you may have a number of rights, including:

(i) the right not to provide your Personal Data to us;
(ii) the right of access to your Personal Data;
(iii) the right to request rectification of inaccuracies;
(iv) the right to request the erasure, or restriction of Processing, of your Personal Data;
(v) the right to object to the Processing of your Personal Data;
(vi) the right to have your Personal Data transferred to another Controller;
(vii) the right to withdraw consent;
(viii) and the right to lodge complaints with Data Protection Authorities.

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

• the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and
• the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

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Nothing in this Policy affects any of your other statutory rights.

To exercise one or more of the rights described in this Policy, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

• we may require proof of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(N) Cookies and similar technologies

We may Process your Personal Data by our use of Cookies and similar technologies.

(O) Direct marketing

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

(P) Contact details

If you have any comments, questions or concerns about data privacy, including the processing of personal data carried out by us, or on our behalf, please send us a message on hello@thepointlegal.com

(Q) Definitions

• "Adequate Jurisdiction" a jurisdiction that has been formally designated by the European Commission or the United Kingdom Government as providing an adequate level of protection for Personal Data.
• "Controller" means the entity that decides how and why Personal Data are Processed.
• "Cookie" means a small file that is placed on your device when you visit our Site. In this Policy, a reference to a "Cookie" includes analogous technologies such as web beacons and clear GIFs.
• "Data Protection Authority" means an independent public authority that is tasked, by law, with overseeing compliance with applicable data protection laws.
• "EEA" means the European Economic Area (the Member States of the European Union, together with Norway, Liechtenstein and Iceland).
• "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• "Sensitive Personal Data" means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
• "Site" means any website operated, or maintained, by us or on our behalf.
• "Standard Contractual Clauses" means template data transfer clauses approved by the European Commission or by a Data Protection Authority for the purpose of transferring data outside of the EEA or the United Kingdom.